This recent post highlighted the 2002 Foreign Corrupt Practices Act enforcement action against Syncor International. It was noted that the $500,000 civil monetary penalty Syncor paid to resolve the action was – at the time – the largest penalty ever obtained by the SEC in an FCPA matter.
Fast forward to the present and such a figure would not even crack the Top 50 civil monetary penalties assessed in an FCPA enforcement action.
Disgorgement and prejudgment interest comprise the bulk of SEC recovery in corporate FCPA enforcement actions (typically 90% or so of overall recovery in most years). However, in approximately 40% of corporate FCPA enforcement actions since 2010 the SEC has assessed a civil monetary penalty and set forth below are the Top 25 civil monetary penalties in FCPA actions.
| Company | Year | Amount |
| 1. MTS | 2019 | $100 million |
| 2. BHP Billiton | 2015 | $25 million |
| 3. Hitachi | 2015 | $19 million |
| 4. ABB | 2010 | $16.5 million |
| 5. SQM | 2017 | $15 million |
| 6. Halliburton | 2017 | $14 million |
| 7. Titan | 2005 | $13 million |
| 8. Mondelez International | 2017 | $13 million |
| 9. ABB | 2004 | $10.5 million |
| 10. Baker Hughes | 2007 | $10 million |
| 11. Las Vegas Sands | 2016 | $9 million |
| 12. Eli Lilly | 2012 | $8.7 million |
| 13. Stryker | 2018 | $7.8 million |
| 14. Qualcomm | 2016 | $7.5 million |
| 15. Juniper Networks | 2019 | $6.5 million |
| 16. Biomet | 2017 | $6.5 million |
| 17. Allianz | 2012 | $5.3 million |
| 18. Sanofi | 2018 | $5 million |
| 19. BNY Mellon | 2015 | $5 million |
| 20. Telefonica Brasil | 2019 | $4.125 million |
| 21. United Technologies | 2018 | $4.0 million |
| 22. AB Volvo | 2008 | $4.0 million |
| 23. Polycom | 2018 | $3.8 million |
| 24.Armor Holdings | 2011 | $3.7 million |
| 25.Fiat | 2008 | $3.6 million |
